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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #98-0287 ([Mr. Tom Perry])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Tom Perry

Location State: FL Country: US

View the Interpretation Document

Response text:

NOV 6, 1998


Mr. Tom Perry                          Ref. No. 98-0287
2867 Stratford Drive
Largo, Florida 33771

Dear Mr. Perry:

This is in response to your letter dated September 18, 1998, requesting clarification on the applicability of the materials of trade exceptions in § 173.6 of the Hazardous Materials Regulations (HMR.; 49 CFR Parts 171-180) to your pool cleaning service. Specifically, you are requesting verification from this Office that you are in compliance with the materials of trade exceptions in § 173.6.

According to your letter you operate a small pool cleaning service that cleans pools and adds chemicals to keep the water sanitized and properly balanced. You state that you transport the following chemicals in direct support of your business:

Trichloroisocyanuric acid, dry, 5.1, UN2468, II
Calcium hypochlorite, hydrated, 5.1, UN2880, II (RQ=10 lbs.)
Hydrochloric acid, solution, 8, UN1789, II
Hypochlorite solutions, (sodium hypochlorite), 8, UN1791, Ill (RQ=100 lbs)

You also state that these materials are properly packaged and marked in packagings not exceeding 66 pounds for solids or 8 gallons for liquids per package, and, the aggregrate gross weight of all materials of trade on the vehicle does not exceed 440 pounds. Your vehicle operators are informed of the presence of the hazardous materials in accordance with § 173.6. It is your understanding that you are in compliance with § 173.6, and are not subject to any other requirements of the HMR except for those in § 173.6.

Your understanding of provisions in § 173.6 as they relate to your business operations are correct. Based on the information provided in your letter) you are in compliance with the materials of trade exceptions.

I hope this answers your inquiry.



Delmer F. Billings
Chief Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.6 Materials of trade exceptions